Version: 1.2

Date: August 3, 2018

Prepared for: USDA OCIO TPA&E

Privacy Impact Assessment 

AGRICULTURAL RISK MANAGEMENT 

(ARM)

Technology, Planning, Architecture, & E-Government
Privacy Impact Assessment 

USDA APHIS, Agricultural Risk Management (ARM) System 

Page 3

Privacy Impact Assessment for the

AGRICULTURAL RISK MANAGEMENT 

(ARM)

August 3, 2018

Contact Point 

Nancy D. Matthews

USDA APHIS

301-851-2059

Reviewing Official 

Tonya G. Woods

APHIS Act Privacy Officer

United States Department of Agriculture

(301) 851-4076
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Abstract 

The Agricultural Risk Management (/\RM) System is a Web-based. Service-oriented system

that will support the operational and analytical needs of USDA APHIS PPQ and the

Department of Homeland Security (DHS) Bureau of Customs and Border Protection (CBP)

Agricultural Quarantine Inspection (AQI) programs. It will also support the diagnostic and

regulatory action needs of Federal and State domestic activities and Smuggling Interdiction

and Trade Compliance (SlTC) activities focused on mitigating the risks associated with

invasive species. The ARM System will replace the existing PPQ IT systems (in particular

the Agricultural Quarantine Activity Systems {AQAS). The PIA is being conducted because

the system will be collecting information from the public that is personally identifiable.

Overview 

The ARM System will support the capabilities for tracking, management and handling of 

inspections of agricultural imports into the United States. The major focus of the system is to 

target those imports that are likely to have pest(s) that introduce risk into the US agriculture.

The functional categories under which data falls within the ARM system are Inspections,

Diagnostics, Regulatory Action, and System Support. In support of the related USDA

processes, The ARM System collects data resulting from the inspection of shipments and

personnel at U.S. Ports of Entry. This information is collected primarily by Customs and

Border Protection (CBP) officers and USDA PPQ inspectors. CBP conducts inspections at

ports of entry, to include sea, air, and land border crossings. PPQ inspectors accomplish

inspections at various Plant Inspection Stations around the country. Inspection data includes

information about the inspection location, shipper, origin and destination of the shipment, the 

shipment mode of transportation, commodity data, and inspected persons data. If pests are 

detected, information is collected concerning the identification of the pest. Diagnostic 

requests may be initiated leading to a final identification of the intercepted pest, as well as a 

determination on the corrective action necessary (such as treatment, destruction, or reexport.). 

Domestic diagnostic requests come from USDA Smuggling Interdiction and Trade

Compliance (SITC) inspections where pests are intercepted from within the U.S. and passed

to ARM for identification support.

Where violations are determined, notifications will be prepared and sent to permit holders,

importers, or brokers. Appropriate information is collected in the ARM System to prepare

these notices.

Numerous administration and reference data tables are maintained to support lookup and

selection of data where needed within the ARM System. This includes taxonomic,

commodity, and shipper/consignee information. Also, user role data is maintained to control

user access to functionality and data.

Section 1.0 Characterization of the Information 
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The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

• Business location and address information

• Business Point of Contact Name

• Shipment and commodity information from shipping documents and invoices

• Name and address information from mail envelopes and labels

• Acknowledgment of notifications of violations

• Data submitted by persons entering the U.S and filling out customs and USDA 

forms

1.2 What are the sources of the information in the system? 

• Shipment and inspection data is input by CBP and USDA PPQ inspectors based 

on data collected from inspection worksheets

• Pest diagnostic data input and treatment recommendations made by USDA 

employees

• Taxonomic data imported from ITIS (one-time import)

• Commodity data collected from shipment documents and invoices provided by 

shippers

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

• Collect, communicate, and analyze inspection data for shipments. conveyances, and

personnel arriving in the U.S.

• Issuing legal notices and non-compliance with regulations

1.4 How is the information collected? 

Information is collected electronically by ARM. Brokers use the Automated Broker 

Interface (ABI) to enter shipment information which is then sent to the CBP 

Automated Commercial Environment (ACE). CBP Agricultural Specialists input 

inspection information from shipment bills of laden or invoices into ACE and this 

information is electronically transferred to ARM.

1.5 How will the information be checked for accuracy? 

Address data will be verified through comparison to addresses previously entered data 

in ARM. Data collected from user supplied data will be scrutinized by CBP officers 
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and USDA inspectors. Organizational names will be compared to existing data in 

ARM.

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

The Plant Protection Act, 7 U.S.C. § 7701 -7772 and 7 U.S.C. ~ 7781-7786; Honey 

Bee Act, 7 U.S.C. § 281-286; and the Animal Health Protection Act, 7 U.S.C. §8301-

8321. POAM 21572 has been created to address the SORN deficiency.

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

Access to data is based on roles assigned on a need to know premise. Role-based 

security and access rights are implemented to protect the confidentiality of 

information. Role-based security includes the use of USDA e-Authentication 

services, which provides user authentication. User roles are granted through web-oftrust mechanisms in place.

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

• Shipment and inspection data is used to validate and verify that all shipments are 

in compliance with trade regulations. 

• Pest diagnostic data is used to determine if shipments require treatments and to 

make recommendations regarding the type of treatment that may be required.

• Taxonomic data is used to collect, communicate, and analyze inspection data for 

shipments, conveyances, and personnel arriving in the U.S., and for issuing legal 

notices and non-compliance with regulations. In addition, the information will 

be used for trend analysis and agricultural risk assessment support.

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

Business Intelligence (BI) tools are used to generate reports, trends, and graphs. 
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2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

Commercial or publically available shipping data is used to identify shipments of 

regulated imported commodities.

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

Access to data is based on roles assigned on a need to know premise. Role-based 

security and access rights are implemented to protect the confidentiality information. 

Role-based security includes the use of USDA e-Authentication services, which 

provides user authentication. User roles are granted through web-of-trust mechanisms 

in place. 

SSL encryption is used to protect data being transferred over the wire. System 

credentials which support access control are protected using strong one-way hash. 

System credentials are obscured while users input their credentials to access the 

system.

Section 3.0 Retention 

The following questions are intended to outline how long information will be retained after the 

initial collection. 

3.1 How long is information retained? 

APHIS will maintain records indefinitely while the records schedule is awaiting 

approval. This qualifier is supported under 36 CFR 120.18.

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

A retention period has not been formally established for data at this time. We are 

working with the APHIS records management officer to establish a data retention

schedule.
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3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 

There is minimal risk associated with the length of time data is retained. The main risk 

is the availability of the information and the length of lime it would take for users to 

perform data mining activities due to the breadth of data.

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture.

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 

N/A

4.2 How is the information transmitted or disclosed? 

N/A

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

N/A

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for information 

sharing external to USDA which includes Federal, state and local government, and the private sector. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 

Data will be shared with DHS CBP. CBP will input inspection results and 

communicate the results to USDA and prepare non-compliance notifications. Reports 

and trends will be shared with CBP for staffing purposes and to allow for DHS to 

make risk-based decisions about the admissibility of certain commodities from other 

countries and their transfer within the U.S.
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5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

Yes. It is not currently covered under a SORN but POAM 27762 has been created to 

address this deficiency. Sharing of personally identifiable information (PII) outside the 

Department is compatible with the original authorities and reasons for data collection 

only if the sharing of such data is associated with Departments and Agencies who 

share or act on behalf of USDA APHIS regulatory and legal authorities. These include 

The Plant Protection Act, 7 U.S.C. § 7701-7772 and 7 U.S.C. § 7781-7786; Honey 

Bee Act, 7 U.S.C. § 281-286; and The Animal Health Protection

Act, 7 U.S.C. §8301- 8321

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

The information is shared electronically with the following security measures for 

safeguarding transmissions. The information exchange is encrypted using FIPS 140-2; 

AES-256 encryption algorithms over the DHS Extranet configured with IPSEC 

encrypted tunnels.

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

Data in the system is accessible to authorized ARM users, managers, system 

administrators, database administrators, and other employees with appropriate access 

rights. Not all data will be accessible by any user; functionality and access will be 

determined and controlled by user roles and an access matrix that is controlled by 

PPQ management. 

Likewise, DHS Customs and Border Protection (CBP) inspectors will also have 

access to the data in this system. Access will be controlled in the same way as for 

USDA users; through eAuth accounts and ARM System user roles applied to an 

access matrix.

Access to data is based on roles assigned on a need to know premise. Role-based 

security and access rights are implemented to protect the confidentiality of 

information. Role-based security includes the use of USDA e-Authentication 

services, which provides user authentication. User roles are granted through web of 

trust mechanisms in place.
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Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information collected, 

the right to consent to uses of said information, and the right to decline to provide information. 

6.1 Was notice provided to the individual prior to collection of 

information? 

APHIS will be issuing a new System of records Notice (SORN) in conjunction with 

this PIA. Notice is also provided through the publication of this PIA on the Internet. 

Additionally, USDA has set up a web site to provide an additional location to view 

published PIA’s http://www.usdagov/wps/portal/usda/usdahome?navid=PRIVACY_

POLICY_ES.

6.2 Do individuals have the opportunity and/or right to decline to provide 

information? 

Generally, the decision to enter into the U.S. or import goods/merchandise into the 

United States is within the discretion of the individual or company. However, United 

States law requires persons seeking to enter the US or to import regulated items to 

provide sufficient information to allow USDA APHIS to determine whether the 

individual poses a risk or to determine whether the imported goods/merchandise pose 

an agriculture or natural resource risk to the country.

6.3 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right? 

Because the submission of information is required for persons seeking to enter the US 

or the import regulated items, restrictions on APHIS use and sharing information is 

limited to the legal requirements set forth in the Privacy Act, Trade secrets Act, and 

the uses of published System of Records Notifications (SORN). Individuals or 

companies do not have the right to consent to the particular use of the information 

collected in ARM. As for the use of the information, once it is presented to APHIS in 

an importation or individual entry, the individual or companies no longer retain rights 

respecting their consent to the use of the information.

6.4 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

As mentioned in 6.1 of this section, APHIS will be issuing a new System of Records 

Notice (SORN) in conjunction with this PIA. Notice is also provided through the 
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publication of this PIA on the Internet. Additionally USDA has set up a web site to 

provide an additional opportunity to view published PIA's

http://www.usda.gov/wps/portal/usda/usdahome?navid=PRIVACY_POLICY_ES.

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their 

information? 

Procedures for individuals to gain access to data maintained in ARM would be 

covered by the respective SORN for this system. In addition, the freedom of 

information act (FOIA) (5U.S.C 522) provides a means of access to the information 

for all individuals, irrespective of the individual's status under the privacy act.

Under FOIA, certain records may be withheld in whole or in part from the requester 

if they fall within one of nine FOIA exemptions. Six of these exemptions most often 

form the basis for the withholding of information by APHIS:

Exemption 2: Protects certain records related solely to APHIS' internal rules and 

practices.

Exemption 3: Protects information that is prohibited from disclosure by other laws.

Exemption 4: Protects trade secrets and confidential commercial or financial 

 Information.

Exemption S: Protects certain inter-agency and intra-agency communications.

Exemption 6: Protects information about individuals in personnel, medical, and 

similar files when disclosure would constitute a clearly unwarranted 

invasion of privacy.

Exemption 7: Protects records or information compiled for law enforcement purposes 

when disclosure (A) could reasonably be expected to interfere with 

enforcement proceedings; (B) would deprive a person of a right to a fair 

trial or an impartial adjudication; (C) could reasonably be expected to 

constitute an unwarranted invasion of personal privacy: (D) could 

reasonably be expected to disclose the identity of a confidential source; 

(E) would disclose techniques and procedures for law enforcement 

investigations or prosecutions, or would disclose guidelines for law

enforcement investigations or prosecutions, if such disclosure could 

reasonably be expected to risk circumvention of the law; or (F) could 

reasonably be expected to endanger the life or physical safety of an 

individual.

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 
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Any individual who wishes to request correction or amendment of any record 

pertaining to him or her contained in a system of records maintained by an agency 

shall submit that request in writing in accordance with the instructions set forth in the 

system notice for that system of records. The Privacy Act requires agencies 

maintaining personal information about individuals to keep accurate, relevant, timely, 

and complete files. If individuals believe ARM contains incorrect information and 

should be amended, they may contact the agency directly to request a change.

7.3 How are individuals notified of the procedures for correcting their 

information? 

Publication of the Systems of Records Notification (SORN) provides information on 

access and amending information collected in ARM. The agency also provides the 

public with information via publically accessible web sites. For example the FOIA 

Reading Room can be accessed at the following we address:

http://www.aphis.usdagov/foialfoia_reading_room.shtml.

7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

Redress is provided.

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

As noted in 7.1 of this section, individuals may seek access to information collected 

in ARM pursuant to FOIA, and as a matter of APHIS policy, redress may be 

requested directly from the agency.

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Access to data is based on roles assigned on a need to know premise. Role-based 

security and access rights are implemented to protect the confidentiality of 

information. Role-based security includes the use of USDA e-Authentication services, 
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which provides user authentication. User roles are granted through web-of-trust 

mechanisms in place.

8.2 Will Department contractors have access to the system? 

Yes

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

APHIS requires all system users to take privacy and cybersecurity on an annual basis. 

The records are stored electronically for verification purposes.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Authority to Operate was granted on 25 August 2015.

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

ARM utilizes robust authentication and authorization via USDA e-Authentication, 

physical access control, firewalls (access control), and intrusion detection systems 

prevent unauthorized access and misuse of data. ARM utilizes audit trails to track 

data inserts and edits for all major data elements and tables within the system. 

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 

on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

Auditing is enabled at the database and web application level which creates logs which 

detail objects accessed by users. Role-based access controls are enabled to provide least 

privilege. Secure Socket Layer (SSL) is used to protect data being transferred over the 

wire. System credentials which support system access control are protected using 

strong one-way hash. Passwords are obscured while users input their credentials to 

access the system.
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Section 9.0 Technology 

The following questions are directed at critically analyzing the selection process for any technologies 

utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

ARM is a web-based application that supports the operational and analytical needs of 

USDA APHIS PPQ and the Department of Homeland Security (DHS) Bureau of 

Customs and Border Protection (CBP) Agricultural Quarantine Inspection (AQI) 

programs.

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

No, integrity, privacy, and security are reviewed in accordance with APHIS IT 

security and privacy policy, and are reflective of the successful transition through 

certification and accreditation, and investment management processes.

Section 10.0 Third Party Websites/Applications

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications.

10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

Yes

10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications?

N/A

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications.

N/A
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10.4 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be used?

N/A

10.5 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be maintained and secured?

N/A

10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

N/A

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications?

N/A

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally?

N/A

10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 

either the creation or modification of a system of records notice 

(SORN)?

N/A

10.10 Does the system use web measurement and customization technology?

N/A

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology?

N/A
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10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

N/A
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Approval Signatures

______________________________ 

 Terry A. Morris

Information System Owner

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Rajiv Sharma

Information System Security Program Manager

Animal and Plant Health Inspection Service 

United States Department of Agriculture

________________________________ 

Tonya G. Woods

Privacy Officer

Animal and Plant Health Inspection Service 

United States Department of Agriculture